OCC Assesses Civil Money Penalty Against Zions

WASHINGTON — The Office of the Comptroller of the Currency announced today the assessment of an $8 million civil money penalty against Zions First National Bank, Salt Lake City, Utah, for violations of the Bank Secrecy Act and the USA Patriot Act as part of a coordinated action with the Financial Crimes Enforcement Network. Concurrent with the OCC’s penalty, FinCEN assessed an $8 million penalty against Zions. Both penalties will be satisfied by a single $8 million payment to the U.S. Department of the Treasury.

The OCC commenced an investigation into the Bank’s former foreign correspondent business and identified deficiencies in its Bank Secrecy Act and anti-money laundering controls, which resulted in violations of law. In particular, the Bank had developed a remote deposit capture product that enabled customers to deposit imaged items electronically from remote locations and marketed the product to high risk customers in 2006 and 2007 without sufficient regard to BSA/AML compliance implications. The Bank exited the foreign correspondent line of business in early 2008, promptly conducted a voluntary look back, and reported suspicious activity.

The OCC has been directing and monitoring the significant enhancements that the Bank has made to its BSA compliance program over the years, and has shared its recent findings and conclusions with FinCEN. "The OCC continues to work with FinCEN and other agencies to ensure compliance with the requirements of the Bank Secrecy Act and USA Patriot Act," said John Walsh, Acting Comptroller of the Currency. "With these actions, we are sending another strong message that banks need to be vigilant and ensure that they have effective anti-money laundering programs in place."